Report on SAPC HOPS Meeting 5 April 2018 The SAPC met with Heads of Pharmaceutical Services from both the public and private sectors. 1. LEGAL SERVICES AND PROFESSIONAL CONDUCT Good Pharmacy Practice rules to be updated Following the publication of the General Regulations in terms of the Medicines and Related Substances Act, 101 of 1965, it is necessary to update the GPP in order to reflect the changes, including the numbering of regulations. Because the Regulations came into immediate effect, the amendment to the GPP will be published for immediate implementation. Board Notices published by the South African Pharmacy Council since September 2017 BN 841 of 2017, dealing with the fees payable to Council in 2018, was published on 27 October 2017. It was updated on 23 March 2018, in BN 43 of 2018, to adjust the fees to reflect VAT at 15%. Two standards were published for implementation in November 2017, viz. BN 183 of 2017, Good Pharmacy Education Standards Higher Education and Training, and BN 184 of 2017, GPP Minimum standard for the sale of HIV self-screening kits. It is anticipated that the finalised 2018 Competency Standards for pharmacists will shortly be published in a Board Notice for implementation. Council elections 2018 The current term of office of all Council members comes to an end on 20 October 2018. It is therefore necessary for pharmacists to elect 9 pharmacists to serve on the next Council. The Minister of Health will appoint the balance of the members. A Notice announcing the elections will be published in the Government Gazette on 6 April 2018 for the 9 elected members. The Notice calls for nominations and nominations will close on 17 May 2018. Nomination forms will be sent out by way of email and will be available to download off the Council website, www.sapc.za.org. The SAPC made it clear that organisations are requested to inform their members of the elections. Pharmacists must be encouraged to participate in the elections, by nominating people who they think are suitable to serve on Council, and then by voting when the time comes. Pharmacists must also be reminded to update their personal details on the Council website, including registered addresses, courier addresses, email addresses and cell numbers. Election timetable: 6 April 2018 Launch of Elections 2018 by publication of a notice in the Government Gazette
17 May 2018 Closing date for nominations End of May Publication of nomination list Beginning to mid-june 2018 Distribution of ballot forms Mid-August 2018 Closing date for ballots End of August 2018 Counting of votes Mid to end September 2018 Publication of the new Council (elected and appointed members) Legislation relevant to pharmacy Guidance for the issuing of licences for pharmacy premises, GNR 1476, was published for comment on 22 December 2017. Comments were submitted and will be reviewed by the relevant NDoH Task Team. Norms and Standards regulations applicable to different categories of health establishments were published for implementation on 2 February 2018. They are published as regulations in terms of the National Health Act, 61 of 2003. Outstanding legislation The SAPC office was asked about the regulations that were submitted to the NDoH seven years ago. These concern CPD, pharmacy technicians and specialists. There has apparently been significant progress and these are now receiving attention from various areas in the NDoH. 2. PRACTICE Amendments to the minimum standard for premises, facilities and equipment Council is reviewing the minimum standard and criteria for another business or practice in a pharmacy and the standard will be published for comment. Minimum standards for the approval of any other facility in terms of regulation 12 of the regulations relating to the practice of pharmacy In 2017, minimum standards specifically relating to the approval of facilities (other than primary healthcare clinics) where a pharmacist s assistant (post-basic) may practise under indirect supervision pharmacy linked dispensing points (PLDP) were published for comment. Because of the substantial comment received, it was decided that revised standard would be published for comment. In reviewing the comments submitted, it became apparent that the majority of stakeholders confused this standard and pick-up points (PUP) for CCMDD. It was decided that a Council resolution on the Requirements and conditions for the distribution of long-term therapy/medicines (chronic medicines) for public sector patients would be published together with the minimum standard to provide clarity to stakeholders.
Amendments to the GPP: Chapter 5: Professional standards for the provision of pharmaceutical services from a pharmacy The Pharmacy Act, 53 of 1974 provides a definition of a pharmacy as any place wherein or from which any service specially pertaining to the scope of practice of a pharmacist is provided. In order to give easier access to the relevant standards, it was decided that in reviewing the GPP, a new chapter, Chapter 5, will be added, Guidelines and/or standards on the provision of pharmaceutical services from a pharmacy will be moved to this chapter. The following approved standards and document will be included: (a) Minimum standards for community or institutional pharmacies providing pharmaceutical services from a mobile unit; (b) Minimum standards for community or institutional pharmacies operating websites; (c) Minimum standards specifically relating to the collection and the delivery of medicines to patients from a Community or Institutional pharmacy; (d) Minimum standards for institutional public pharmacy operating a Remote Automated Dispensing Unit (RADU); and (e) Requirements and conditions for the distribution of long-term therapy/medicines (chronic medicines) for public sector patients. Inspection of pharmacies: grading Inspection grading was introduced to pharmacies in 2013 as an audit tool to monitor and compare the level of compliance across all categories of pharmacies to Good Pharmacy Practice (GPP) standards. The inspection grading was developed on the following principles: (a) questions within the inspection questionnaires are weighted per section; (b) all questions in a specific section have the same weighting; (c) the final percentage compliance of a pharmacy is determined by the sum of the percentage compliance of all the individual sections divided by the number of sections; (d) every section contribute to the same percentage to the final percentage compliance of a specific pharmacy; (e) the overall effect of the application of the weighting per question is cancelled out. It must be noted that all questions in the inspection questionnaire are based on existing legislation. Council does not require input from pharmacists as they are required to be compliant with all relevant legislation. When the grading system was introduced, It was envisaged that over time, all sections will be weighed equally as the GPP recognises all sections as equally important. The North-West University (NWU) was tasked to evaluate the grading model implemented where different sections within the inspection questionnaires carry different weightings. A grading task team was appointed by Council to interpret the
results and advice practice committee. Some of the problem areas identified when interpreting the results are summarised in Table 1. Table 1: Problem areas in different pharmacy sectors where there is high level of non-compliance Sector Community Pharmacies Private institutional Pharmacies Public Institutional Pharmacies Wholesale Pharmacies Manufacturing Pharmacies Section in the questionnaire obtained an average compliance of less than 80% Written standard operating procedures Registration Promotion of public health References No section in the questionnaire obtained an average compliance score of less than 80% Registration Registration Reference Pharmacy details No section in the questionnaire obtained an average compliance score of less than 80% It was noted that the grading, with its implications of frequency of inspection, has resulted in an improvement of compliance by some pharmacists where Grade C was allocated. It has also identified the problem areas in different types of pharmacy. Timing of inspections In the beginning of each year, the Office of the Registrar determines pharmacies due for inspection. The frequency of a pharmacy inspection is dependent on the outcome of the previous grading, which is an indication of the level of compliance. Table 2 summarises pharmacy grading and inspection cycles. Table 2: Inspection cycle per pharmacy grade Grades Inspection findings Inspection cycles A No/few shortcomings identified Three (3) year cycle B Minor shortcomings Two (2) year C identified Critical shortcomings identified cycle One (1) year cycle
Although all pharmacies that are due for inspections are published on Council s website annually, section 30(A) of the Pharmacy Act (Act 53 of 1974) empowers Council to conduct an inspection at any time reasonable to perform an inspection. Officers are required to conduct inspections for all previous grade C pharmacies allocated to them by the end of June for that year. Officers may conduct an inspection allocated to them at any time of the year, regardless of the date and month the previous inspection was conducted. In July 2017, it was decided that inspectors would be instructed to conduct inspections during normal trading hours, that is, 09:00 to 16:00 on weekdays which increases the chance that the RP will be present in the pharmacy. It was also agreed that the name for inspectors would be changed to Monitoring / Training Officers when conducting monitoring and training inspections and Compliance Officers for the purpose of conducting disciplinary inspections. It was pointed out that any pharmacist working in the pharmacy should be aware of all SOPs and should be instructed by the RP on where everything that is needed for an inspection is kept. Ideally, the RP should download the inspection questionnaire and perform regular self-audits. Reference material The office circulated the references list to all responsible pharmacists in a survey format and requested input on the relevance of the proposed list. Pharmacists were also asked to suggest additional suitable reference materials for their current practice of pharmacy. It was decided to extend the survey to all pharmacists, interns, pharmacy support personnel and owners. It was pointed out that it is unlikely that a final decision on the reference list will be made before 2020, so pharmacists must continue to be compliant with the current list, which is published as part of the GPP. Inspection of pharmacies: requirement for responsible pharmacists to respond to shortcomings identified during an inspection Effective from 2017, all responsible pharmacists who fail to respond to the shortcomings for Grade A and B will be referred to legal services and professional conduct for disciplinary action. Responses must be submitted online on the secure site of the SAPC website. Guidelines for responding to shortcomings are available on the website under the customer services link. Pharmacists need to understand that the report is accessible immediately after the inspection. Many pharmacists didn t realise that they had to respond to the report on line and not in an email.
Pharmacies that obtain Grade A or B that have responded to identified shortcomings may train pharmacist interns and pharmacy support personnel upon applying for premises approval for training and paying the relevant fees. All Grade C pharmacies are referred to legal services and professional conduct, where the report goes through a screening process. No disciplinary action is taken the first time that the pharmacy receives Grade C as it is anticipated that the pharmacist will take remedial action. If the shortcomings are not addressed by the next inspection, it will be referred for disciplinary action. Serious shortcomings, such as the absence of a pharmacist, will be referred directly to the disciplinary process. Post inspection survey Council has further developed a survey that must be completed by a pharmacist who was present at the time of inspection. Upon completion of the inspection, the officer captures the inspection online and communication is sent to the pharmacist who was present during an inspection to complete the survey. The responses to the survey are used by the Office during training of officers. Appointment and training of officers Pharmacists wishing to act as monitoring/training officers must have at least ten years experience. Training is conducted three times a year. Maintenance of Council registers for pre-25 April 2003 pharmacies Section 22 of the Pharmacy Act was amended in 1987 but only came into effect on 25 April 2003, when the Regulations relating to the ownership and licensing of pharmacies commenced. At that time, all persons registered to carry on the business of a pharmacy were deemed to be licensed in terms of the new section 22(1) of the Act. Pre-25 April 2003 pharmacies are those that: (a) were registered as pharmacies prior to 25 April 2003, in the manner as prescribed prior to the Pharmacy Amendment Act, 88 of 1997; (b) do not have a pharmacy licence issued by the Department of Health; and (c) are deemed to be registered in terms of section 22(9). Prior to the licencing of pharmacies in terms of section 22 of the Act and the corresponding regulations, pharmacies were required to be registered with the South African Pharmacy Council. There were no criteria for inter alia the determination of need for the pharmaceutical services in the respective areas. This changed with the implementation of the Ownership Regulations. If a pharmacy thus moved premises, the pharmacy owner was required to notify Council of such move, and a new certificate of registration was issued and the premises inspected. Since the amendment to section 22 and the Ownership Regulations, pharmacies that: (a) change owners; and/or (b) relocate to different premises, are required to apply to the Director General for a pharmacy licence, with all the requirements of section 22 and the Ownership Regulations for a pharmacy licence.
The Council and the NDoH realised that pharmacies that were deemed to be licensed, without actually having a licence issued in terms of section 22, are changing ownership or relocating without any formal application to do so and are thus not necessarily meeting the criteria of the Ownership Regulations. This is possible because the certification and recording system of these pharmacies did not clearly state the address of the pharmacy and the details of the owner, as is currently the requirement. In addition, the NDoH has no formal record of these pharmacies bearing the licence number system used. This problem is further compounded by the fact that the NDoH is not in a position to know whether there was a need for pharmaceutical services at the time of applying for relocation in terms of the criteria for a new licence. Council resolved in February 2015 that: (a) all pharmacies registered prior to 2 May 2003 be required to obtain a licence from the National Department of Health and to record such licences with SAPC; and (b) both the fee for the application of the licence and subsequent recording thereof not be paid provided that the pharmacy was still at the same premises as at 2 May 2003 and the ownership had not changed. The Office of the Registrar therefore wrote letters to owners and responsible pharmacists for pre-may 2003 pharmacies requesting them to confirm the following: (a) if the physical address of the pharmacy reflected on Council s register is correct as per the actual physical address of the pharmacy; and (b) if the pharmacy is still owned by the same owner as reflected on Council s register. Council requested this information for maintenance of the register of pharmacies in anticipation of the project for the issuing of licenses for pre-may 2003 pharmacies, where there was no change or ownership or relocation after 2003. If there have been changes to either location or owner (a) the pharmacy owner must apply for a pharmacy premises licence at the Department of Health for the particular change, using the attached application form and complete the SAPC online application form accessible on the secure site of the website: www.sapc.za.org; and (b) there will be a fee for application and a fee for recording, as normal. If there have been changes to both the location and owner, the pharmacy owners must (a) complete two applications and submit the applications together; (b) clearly indicate on the floor plans and site plans submitted, that they are for the new address (pre-may 2003 did not have floor plans and site plans); and (c) submit an affidavit that the pharmacy was relocated and changed ownership since May 2003, without informing Council. SAPC will evaluate the floor plans for the new address, NDoH will issue both licences and the owner will be expected to complete recording for relocation and attach both licences to SAPC for recording. There will be a fee for the two
applications for licences and a fee for recording for relocation (two licences should be attached). Note: the application for relocation will not be processed unless the applicant is in possession of both licences. The table below indicates the numbers of pre-may 2003 pharmacies (per category) without licences that were on Council s register as at 30 August 2017. Table 1 Count of Y Category Numbers Community Pharmacy 908 Consultant Pharmacy 4 Institutional Private 34 Manufacturing Pharmacy 66 Wholesale Pharmacy Private 67 Grand Total 1079 The Office of the Registrar met with a representative from the Department of Health on 14 March 2018 to discuss the process to be developed for the issuing of licences to affected pharmacies. The profession will be informed timeously once the process has been finalised. 3. EDUCATION The Pharmacist s Assistant qualification will come to an end on 30 June 2019. The Pharmacy Technician qualification is currently in the process of being registered with the South African Qualifications Authority. The qualification will be registered within two sub-frameworks, viz. Higher Education Qualifications and Occupational Qualifications sub-frameworks. 4. CPD, PRE-REGISTRATION AND REGISTRATION Learners who have exceeded 30 months The maximum period permitted for a learner pharmacist s assistant to complete either of the two learning programmes (basic and post-basic) is 30 months. Learners who have exceeded 30 months are removed from the register until the end of a twoyear cool-off period when they can re-register for the qualification. In view of the fact that the qualifications will expire soon, learners who request an extension of registration be considered for a 7 months extension on submission of a motivation, tutor confirmation and a record of modules completed from the provider of education and training. The 7 months extension is granted on merit. Council records show that there are about 600 registered active learners who have already exceeded 30 months and have not applied for extensions. The Office will be facilitating their removal from the register which may result in unregistered persons performing the scope of practise of a pharmacist s assistant in facilities. The Office
will communicate with the employers of the affected learners as well as the candidates before they are erased. Online registration processes Council has implemented online processes for most registration applications. Applicants are expected to apply for registration online where they are and only come to Council offices to collect the registration certificate if needed urgently, otherwise certificates get couriered to applicants. The intern registration certificate is available online, therefore interns need not come to the Office for certificates. The turn-around for processing of applications is 14 days with other applications, such as intern, CSP, CSP completion and recording applications, being prioritised and having a reduced turn-around time. Council has prioritised the turn-around time for interns and CSPs. It is disturbing to note that more than twenty CSPs have not been released from the private sector because no sign-off letter, stating that they have completed their community service, has been received. Recognition of qualifications obtained outside South Africa The NDoH is currently reviewing its foreign workforce policy. Continuing Professional Development for interns As the submission of CPD activities on the online platform is one of the components of the pre-registration evaluation, interns are required to submit 8 CPD entries from competence standards 1-7 (compulsory) and either 8, 9 or 10 (optional) and be competent in at least 6 of them. The deadlines for submission of intern CPD entries are indicated in Table 1. Results are released every two months from the deadline. CPDs submitted after the deadline will be assessed and released in the subsequent period. Council has resolved that there be no CPD assessments in December and this has been emphasized to interns and tutors during the workshops. If interns are not competent in CPDs by 30 November 2018, they may resubmit their corrected CPDs but they will wait for the two-month assessment period starting after 7 January 2019. Table 1: CPD submission deadlines for 2018 (a) According to Council Policy, appeals must be submitted within one calendar month after the release of the results. LAST DATES FOR SUBMISSION OF CPD ENTRIES (b) There will be no CPD assessments in December. Entries submitted after 29 October 2018 will only be assessed in January 2019. (c) Entries submitted after the deadline will be assessed in the next assessment cycle.
Verification of intern CPD entries by tutors For 2017, tutors were provided with read-only access to their intern CPDs in order to guide interns and to prepare tutors for full implementation of this process in 2018. Online tutor verification of their intern CPDs has now been implemented for all 2018 interns. Once the interns have submitted their CPDs, these are auto-allocated to their tutors to verify them, guide the intern to make necessary corrections and then submitted by the tutor for assessment by Council. Workshops for interns and/or tutors Council conducts workshops for interns annually to provide them with information on pre-registration requirements and training on CPDs and examinations. The workshops are conducted in all provinces. The intern/tutor workshops which focus on CPDs are conducted in March and must be attended by both tutors and interns. The pre-registration workshops which focus on the pre-registration examination is conducted before the June exam. Interns and tutors must book online on Council s website to attend the workshops. All registered active interns are required to attend the workshops as any changes in guidelines, assessment criteria and timetables are also communicated during workshops. The 2018 intern and tutor manual with all the pre-registration information is available on the SAPC website. All workshop presentations are made available on the SAPC website once workshops are completed. The Office is also working on developing webcasts for the workshops. The Office has also been receiving requests for additional workshops from various stakeholders. As Council only budgets for one CPD workshop and one pre-reg. workshops for the year, stakeholders will be assisted if they will carry all the costs for the additional workshops. Pre-registration examinations Council conducts examinations as part of the pre-registration evaluation for pharmacist interns. For 2018, the frequency of the pre-registration examinations has been increased to four and exams will be conducted on 3 March, 2 June, 1 September and 24 November 2018. Council is in the process of reviewing both the professional and pre-registration examinations, and the frequency and the format of these examinations might change depending on the outcome of the review. Council has introduced an oral examination for interns who have failed the examination two or more times, are competent in all their CPDs, submitted all the required progress reports that are favourable, completed 365 days and attended the revision class arranged by the Office of the Registrar. The oral exam was subsequently held on 20 September 2017. The date for the 2018 oral exam will be determined by the Office and communicated to the affected candidates. Completion of internship Once interns have complied with all the pre-registration requirements, i.e. completion of 365 days under a tutor, submission of favourable progress reports by the tutor, competence in at least 6 of the 8 CPDs submitted and success in both papers of the pre-registration examination, they are released from the register of interns and
become eligible for registration as pharmacists for the purpose of performing pharmaceutical community service. Interns who have not met the pre-registration requirements by the end of 365 days, are kept in the register of interns until they comply with all the requirements. Failing exams and CPDs are the most common reasons interns cannot be progressed at the end of 365 days. Some of these interns get released by their tutors to make way for new interns and, consequently, their employment gets terminated. This is a challenge because both the pre-registration examination and the CPDs assess practice and require interns to be at the workplace to become competent in them. Interns are expected to either request extension of their employment contracts or seek another employment under a new tutor so that they can pass the exams and/or CPDs. Council acknowledges the challenges posed by interns repeating exams and CPDs to the workplace, and has considered allowing interns who cannot find internships (on motivation) to work as pharmacist s assistants in the category postbasic until they pass the exams. However, interns who are not yet competent in CPDs need tutors to sign off their CPDs. Competency standards for pharmacists in South Africa Council developed the first competence standards for pharmacists in 2006. These competence standards were based on the unit standards specified in the Regulations Relating to Pharmacy Education and Training and are being used in CPDs and the pre-registration examination. Council in 2015, resolved that the competence standards and outcomes be reviewed in line with current practice, the revised BPharm qualification 2012/3 to 2018, and the International Pharmaceutical Federation (FIP) global competency framework (2012). A panel of experts from practice was appointed to assist Council with updating and developing the competence standards. During the development process, the existing competence standards were changed to competency standards which incorporate both educational outcomes and behaviours instead of a stand-alone competence structure. The new competency standards are also presented according to the levels of practice. On approval by Council, the drafted competency standards were published for public comment and the comments received were incorporated to the document. Council on 13-15 February 2018 approved the competency standards for implementation and these are in the process of being published in board notice. The implementation of the new competency standards means that the BPharm qualification, the CPDs and the pre-registration examinations must be revised to align with them. Council has started processes to align with the new competency standards. Review of internship Council has appointed a task team to review internship. The task team has met several times and developed the re-engineering internship document which outlines the project plan. The project is in progress.
Release of community service pharmacists Council has previously allowed the release of community service pharmacists (CSPs) by the HOPS to start from 15 December so that CSPs can register timeously in their new roles at the beginning of the following year. On release by the HOPS, Council uplifts the community service limitation on the registration as a pharmacist and the candidate becomes free to work in any sector of pharmacy. In the workshops and the Intern Manual, Council emphasises that the minimum period for the CSP role is twelve months. The Office of the registrar has received complaints from some of the employers that, once released, CSPs do not meet their contractual obligations in terms of working until the end date of their contracts. On 11/12 October 2017, Council discussed this matter and resolved that (a) these matters should be considered by Committee of Preliminary Investigation (CPI) on a case by case basis, who could potentially impose penalties on pharmacists registered for the purpose of performing pharmaceutical community service (CSP) that are non-compliant; and (b) the system be amended to allow Heads of Pharmaceutical Services to release CSPs only after 365 days, based on the majority vote taken at the HOPS meeting. 5. COMMUNICATION AND STAKEHOLDER RELATIONS 3 rd National Pharmacy Conference (3-6 October 2019) The 3 rd National Pharmacy Conference will take place at Sun City from 3-6 October 2019. It is planned that the charity Golf Day will tee off on Wednesday, 2 October 2019 at the Gary Player Golf Course, Sun City. The future of South African pharmacists and pharmacy professionals dictates that all pharmacy stakeholders should be engaged, and plugged in to the technological changes to become catalysts for change. This is also the theme of the 2019 3 rd National Pharmacy Conference. A highlight of the conference will be the 2019 National Pharmacy Pioneer Awards in honour of those pharmacy professionals who have delivered exceptional service and made a difference in their communities. Delegates can register online for the conference at www.sapcconference.za.org The registration fees for the conference are indicated in the table below. More information is also available on the conference Facebook page: https://www.facebook.com/3npcsapc/
Delegate registration fees Registration Category Pharmacists, nonpharmacists or other professionals Early bird registration fee R4,425 R5,090 Pharmacy Students R2,215 R2,545 Pharmacy Support Personnel R3,320 R3,820 Day registration R2,235 R2,850 Moving to 2030 the pharmacy profession should address: Late Registration fee Delegates can pay registration fees in instalments until end of Early Bird registration The role of pharmacist in collaborative practice or group practice The role of pharmacist in primary health care setting Use data, information and information technology to improve the quality, safety, efficiency and effectiveness of healthcare delivery Communication which involves verbal, non-verbal, listening and writing skills and the use of multimedia platforms Community engagement = work-based learning To ensure that the programme of the 3 rd National Pharmacy Conference (3-6 October 2019) at Sun City responds to their career development needs, young South African pharmacists and pharmacist support personnel are invited to complete a short online survey, available at this link: https://s.surveyplanet.com/hy4we5xjg The production of future pharmacists dictates that all pharmacy stakeholders be plugged-in, engaged becoming a catalyst for change.. September National Pharmacy Month National Pharmacy Month is observed every September in South Africa. The 2018 theme for National Pharmacy Month is Use medicines wisely The aim of National Pharmacy Month is to strengthen the profession s efforts to improve consumer awareness of the crucial role pharmacists play in attending to their daily healthcare needs, and to promote an understanding of the importance of pharmacists in the provision of quality healthcare. Media tools and key messages are currently being crafted and will include a Pharmacy Month official poster, flyers in 8 official languages, PowerPoint information slides for digital display in pharmacies, and media releases.
Pharmacy professionals are encouraged to promote this year s theme to patients. Some activities to consider are exhibition stands, presentations, visits (schools, hospitals, gyms, old age homes), competitions, press releases, information slips, emails, Facebook, Twitter etc. Artwork will be available for download from www.health.gov.za, www.sapc.za.org, and www.pssa.org.za.